Rosenthal v. Town of Poland

CourtSuperior Court of Maine
DecidedJanuary 15, 2021
DocketANDap-19-17
StatusUnpublished

This text of Rosenthal v. Town of Poland (Rosenthal v. Town of Poland) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rosenthal v. Town of Poland, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE SUPERIOR COURT ANDROSCOGGIN, ss DOCKET NO. AP-19-17

Marla Rosenthal, u) ) Plaintiff/Appellant, ) ) V. ) Order on Appeal ) Town of Poland1 , et al., ) ) Defendants/Appe/lees, ) ) And ) ) BSE Swamp Rentals, LLC, ) ) Intervenor. )

This matter is before the court on Plaintiff/Appellant's complaint pursuant to M.R. Civ.

P. SOB for review of the action taken by the Poland Board of Appeals on October 21, 2019

denying her appeal of the Code Enforcement Officer's denial of a permit for a dock.

Factual and Procedural History

Plaintiff is the owner of property at 45 Garland Swamp Road in Poland, Maine.

Although her property does not have frontage on Tripp Pond, it abuts waterfront property at 49

Garland Swamp Road now owned by Intervenor BSE Swamp Rentals. The 1987 deed to

Plaintiff conveys to her the following:

A right-of-way Eight (8) Feet in width southwesterly of and adjacent to land conveyed to the said Cohen bounded southeasterly by the northwesterly line of the above described premises and northwesterly by low water mark of Tripp Pond.

1 The caption is corrected to "Town of Poland" instead of "Inhabitants of the Town of Poland". See note

2, Brief of Town of Poland.

1 This right-of-way to Tripp Pond travels over the property of Intervenor BSE; that easement has

appeared in deeds going back decades. The servient estate contains 69 feet of shore frontage on

Tripp Pond, including the 8 foot right of way. The deed is silent whether a dock is a

contemplated use of the easement.

On July 24, 2019, the Poland Code Enforcement Officer (CEO) received a complaint that

Plaintiff had installed a dock in the lake in front at the easement. On the same day, the CEO

issued a Violation Notice and Stop Work Order regarding the dock. On July 25, 2019, Plaintiff

submitted a Shoreland Project Permit to the CEO, requesting a permit to construct an 8-foot

aluminum dock with four posts. The CEO denied the application on July 31, 2019, and Plaintiff

appealed the denial to the Zoning Board of Appeals (the Board) on September 10, 2019.

Following a public hearing on October 16, 2019, the Board denied Plaintiff's appeal.

The Board concluded that the Poland Comprehensive Land Use Code [Code] does not allow for

more than one dock per lot because the shore frontage for the lot was 69 feet. A second dock

would be a non-conforming use. Therefore, to the extent there had been a second dock there in

the past, any right to that use was extinguished because it had been more than twenty years since

it had been there.2 The Board also found that the proposed dock would interfere with an existing

developed or natural beach area and therefore was not permitted. Plaintiff then filed this timely

complaint for review of that decision pursuant to M.R. Civ. P. 80B.

2Plaintiff conflates two issues in arguing that her right to a dock was not extinguished. The passage of more than one year does not affect the grant of the easement as between the holders of the servient and dominant estates; it still exists. Rather, it affects only whether the particular use is grandfathered if it is otherwise not permitted under the Poland Code. The Board never found that her easement rights were extinguished, nor could it do so. See, e.g., Tomasino v. Town of Casco, 2020 ME 96 l/7

2 Standard ofReview

Review of administrative decision-making is deferential and limited; the decision is

reviewed for abuse of discretion, errors of law, and findings not supported by substantial

evidence in the record. Wolfram v. Town ofNorth Haven, 2017 ME 114 l[7. The court will

affirm the findings if they are supported by any competent evidence. Beal v. Town of Stockton

Springs, 2017 ME 6 lf26. The Board's interpretation of town ordinances is reviewed de novo as

a matter of law. Tomasino v. Town of Casco, 2020 ME 96 l[5. The Plaintiff/Appellant has the

burden of showing that the record evidence compels a contrary conclusion. Tarason v. Town of

S. Berwick, 2005 ME 30 lf6.

Analysis

Plaintiff argues that she has a right to construct a dock pursuant to the terms of the

easement. This argument is misplaced and indeed of little consequence to the analysis. Plaintiff

correctly notes that 33 M.R.S. § 459 does not apply to this case; it only applies to rights-of-way

created after January 1, 2018. However, it also does not mean that rights-of-way created before

that date necessarily carry a right to construct a dock: it simply means that the language of the

easement governs. As noted above, the plain language of the deed gives Plaintiff access to the

lake. It does not, however, address the full scope of the use to be made of it. Thus, the language

may be considered ambiguous and resort had to extrinsic evidence in order to determine whether

she has the right to construct a dock. E.g., Badger v. Hill, 404 A.2d 222, 225 (Me. 1979). That

evidence, however, is not before the court, nor was it determined by the Board. Indeed, the

Board had no "jurisdiction, authority, or expertise" to determine the scope of an easement and it

would have been error had it done so. Tomasino v. Town of Casco, 2020 ME 96 l[7.

3 The scope of the easement is also not germane to the Board's decision because even if

she has a deeded right to construct a dock, the use is still governed by the Poland Code. The

deeded easement can only grant Plaintiff rights enforceable against the servient estate; she must

still comply with zoning laws.

Plaintiff also makes much of the fact that her family had maintained a dock at the

easement in the past. Nonetheless, the Board's finding that there had been no dock for more than

20 years is supported by the record; indeed, it is not seriously disputed. If the use is a non­ 3 conforming use, therefore, it is no longer permitted as a grandfathered non-conforming use •

Once again, the issue remains whether the use is permitted by the Poland Code.

Section § 508.27.D of the Poland Code specifically governs the placement of docks.

Pursuant to § 508 .27.D .3 of the Poland Code, the "location [of a dock] shall not inte1fere with

existing developed or natural beach areas." The Board concluded that the dock inte1fered with

an existing developed or natural beach area, and as such was not allowed under§ 508.27.D.3. In

her original brief, Plaintiff did not even argue this issue except in passing, which is the

equivalent of not arguing it at all. In her reply, Plaintiff argues that the dock was in the water

and not on any beach area, but that is not the standard. The ordinance refers to interference with

the beach area, which is far broader than actual placement on the beach area. The Board found

that a neighbor, Mr. Beaulieu, testified that the dock interfered with a beach area. The records

also contains a letter to the Board from Katherine Carroll, another abutter, stated that Plaintiff

(through Mr. Rosenthal) was blocking the small section of beach which exists between 43

Garland Swamp Road and 49 Garland Swamp Road at Plaintiff's right-of-way. The letter from

3 Pursuant to § 504.4.B of the Poland Code, "La] lot ... on which a legal nonconfonning use is discontinued for a period exceeding one(]) year ...may not again be devoted to a non-conforming use."

4 Bill Aube also described that when the Plaintiff's dock was there it made it difficult for anyone

to use the beach.

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Related

Badger v. Hill
404 A.2d 222 (Supreme Judicial Court of Maine, 1979)
Tarason v. Town of South Berwick
2005 ME 30 (Supreme Judicial Court of Maine, 2005)
Hollie A. Beal v. Town of Stockton Springs
2017 ME 6 (Supreme Judicial Court of Maine, 2017)
Steven Wolfram v. Town of North Haven
2017 ME 114 (Supreme Judicial Court of Maine, 2017)
Mark Tomasino v. Town of Casco
2020 ME 96 (Supreme Judicial Court of Maine, 2020)

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Bluebook (online)
Rosenthal v. Town of Poland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rosenthal-v-town-of-poland-mesuperct-2021.